New Uniform Guidance

New Uniform Guidance
Combines the requirements of OMB
Circulars A-21, A-87, A-110, A-122, A-89,
A-102, A-133, and A-50 into a
streamlined format.
*NOTE: Some of the slides in this presentation were taken
from a COFAR webinar conducted on January 27, 2014
Objectives
• Streamline guidance for Federal Awards to
ease administrative burden
• Strengthen oversight over Federal funds to
reduce risks of waste, fraud, and abuse
• Increase efficiency and effectiveness of Federal
awards to ensure best use of the more than
$500 billion expended annually
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WHAT HAS CHANGED?
The Office of Contracts and Grants is in the
early stages of reviewing and comparing the
Uniform Guidance to the existing OMB
Circulars. Communication and training will
be provided to campus at the completion of
our review.
A highlight of changes already noted are as
follows:
Subrecipients Monitoring and Oversight
Requirements for Pass-through Entities
 200.331, Requirements for pass-through entities
 Includes audit responsibilities that were in A-133
• The pass-through entity must:
• Put specific information in the subaward, including indirect cost
rate
• Do a risk assessment to determine appropriate subrecipient
monitoring AND must monitor subrecipients
• Consider if specific subaward conditions are needed
• Verify subrecipients have audits in accordance with Subpart F
• Make any necessary adjustment to the pass-through entity’s
records based on reviews and audits of subrecipients
• Consider actions to address subrecipient noncompliance
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Information Contained in a Subaward
• Following information must be identified to subrecipient
at time of award and put in the subaward (and when
changes are made to the subaward) (200.331(a)):
• Federal award identification, e.g., DUNS number
• Indirect cost rate for the Federal Award (including if
the de minimus rate is charge per 200.414 Indirect
(F&A) costs) Requirements imposed by the passthrough entity
• Requirement to provide access to records for audit
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Evaluating Subrecipient Risk to
Determine Appropriate Monitoring
 The pass-through entity must evaluate each
subrecipient’s risk of noncompliance with Federal
statutes, regulations, and the terms and conditions of the
subaward for the purpose of determining appropriate
subrecipient monitoring, which may include
consideration of factors such as (200.331(b)):
 Prior experience with same or similar subawards
 Results of previous audits
 Whether new or substantially changed personnel or
systems
 Extent and results of Federal awarding agency
monitoring
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Required Subrecipients Monitoring
Procedures
• When monitoring of subrecipients, the pass-through entity must
(200.331(d)):
• Review reports required by the pass-through entity
• Follow-up to ensure subrecipient takes appropriate action on
all deficiencies pertaining to the subaward from the passthrough entity identified through audits, on-site reviews, and
other means
• Issue a management decision for audit findings pertaining to
subawards made by the pass-through entity
• Not new requirement – taken from A-133
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Additional Subrecipient Monitoring
Tools
• Following tools may be useful, depending upon the risk
assessment (200.331(e))
• Providing subrecipient training and technical
assistance
• Performing on-site reviews
• Arranging for agreed-upon-procedures engagements
under 200.425, Audit services [in Cost Principles]
• No listed tool is required nor is the list of tools all
inclusive
• Determination on which tools is a matter of judgment for
the pass-through entity based upon its assessment of
risk
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Cost Principles
200.413 – Administrative Costs
• Should normally be treated as indirect (F&A) costs
• May be charged as direct cost if ALL of the following
are met:
• Must be integral to a project or activity
• Individuals involved can be specifically identified
with the project or activity
• Such costs are explicitly included in the budget or
have prior written approval of the Federal awarding
agency
• The costs are not also recovered as indirect costs
Cost Principles
• 200.414 - Indirect (F&A) Costs
• Federal acceptance of approved IDC
rate(s)
• New de minimis rate
• One time extension of up to 4 years
Cost Principles
• 200.414 - Indirect (F&A) Costs
(continued)
• Federal awarding agencies must accept
approved negotiated indirect cost rates under
200.414 (c)(1) unless a different rate is required
by Federal statute or regulation, or when
approved by a Federal awarding agency head or
delegate based on documented justification as
described in paragraph (c)(3) of this section.
Cost Principles
• 200.414 - Indirect (F&A) Costs
(continued)
A 10% de minimis IDC rate available is now available under
§200.414 (f) – It says, “ any non-Federal entity that has
never received a negotiated indirect cost rate, except for
those non-Federal entities described in Appendix VII to Part
200 . . . may elect to charge a de minimis rate of 10% of
modified total direct costs (MTDC) which may be used
indefinitely. Importantly, if chosen, the non-Federal entity
must use the 10% rate on all federal awards until the entity
negotiates an approved rate with their cognizant agency.
Cost Principles
• 200.414 - Indirect (F&A) Costs (continued)
• (g) Any non-Federal entity that has a
federally negotiated indirect cost rate may
apply for a one-time extension of a current
negotiated indirect cost rates for a period of
up to four years. This extension will be
subject to the review and approval of the
cognizant agency for indirect costs. If an
extension is granted the non-Federal entity
may not request a rate review until the
extension period ends.
Cost Principles
• 200.419 - Cost Accounting
Standards And Disclosure
Statement
• Was not eliminated
• Threshold for CAS raised to $50M
• Streamlined review for changes to
reduce the risk of non-compliance and
audit findings
Selected Items of Cost
• 200.430 – Compensation – Personal
Services
• Strengthen Internal Controls
• Removed Examples
• Federal Agencies may approve methods
for blended/braided funds
• Use of institutional base salary for IHE
Selected Items of Cost
• 200.432 – Conferences
• Requires conference hosts/sponsors to
exercise discretion and judgment in
ensuring that conference costs are
appropriate, necessary and managed in a
manner that minimizes costs to the Federal
award.
• Allows costs of finding local dependent
care
Selected Items of Cost
• 200.438 – Entertainment Costs
• Unallowable unless
1. Those costs have a programmatic purpose
and are authorized in the approved budget
for the federal award, or
2. Those costs have prior written approval
from the federal awarding agency
Selected Items of Cost
• 200.474 – Travel Costs
• Provides that temporary dependent
care costs that result directly from
travel to conferences and meet specified
standards are allowable.